Privacy policy

Respecting the provisions of current legislation, Graspway undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws that incorporate this privacy policy

This privacy policy is adapted to current Spanish and European regulations regarding the protection of personal data on the Internet. Specifically, it respects the following standards:

• Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, concerning the protection of natural persons with regard to the processing of personal data and the free movement of these data (GDPR).

• Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.

• Royal Decree 1720/2007, of December 21, which approves the Regulations for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).

• Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSI-CE).

Identity of the person responsible for the processing of personal data

The person in charge of the processing of the personal data collected in Graspway is: OPEN SISTEMAS DE INFORMACION INTERNET SL, provided with NIF: B83513705 and registered in: Mercantile Registry of Madrid with the following registry data: Protocol No. 2003/138 / N / 16 / 01/2003. Contact details are as follows:

Direction:

Calle Salvatierra 4, 28034, Madrid (Spain).
Contact phone: +34 902107396
Contact email: info@opensistemas.com

Data Protection Delegate (DPD)

The Data Protection Delegate (DPD, or DPO) is responsible for ensuring compliance with the data protection regulations to which Graspway is subject. The User can contact the DPD designated by the Treatment Manager using the following contact information: osims@opensistemas.com.

Registration of Personal Data

The personal data collected by Graspway, through the forms extended on its pages, will be entered in an automated file under the responsibility of the Data Controller, and duly declared and registered in the General Registry of the Data Protection Agency that can be consulted at the website of the Spanish Agency for Data Protection (https://www.aepd.es/), in order to facilitate, expedite and fulfill the commitments established between Graspway and the User or the maintenance of the relationship established in the forms that it completes, or to attend a request or consultation of the same.

Principles applicable to the processing of personal data

The processing of the User's personal data will be subject to the following principles set forth in Article 5 of the GDPR:

• Principle of legality, loyalty and transparency: the consent of the User will be required at all times prior completely transparent information of the purposes for which personal data is collected.

• Principle of limitation of purpose: personal data will be collected for specific, explicit and legitimate purposes.

• Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.

• Principle of accuracy: personal data must be accurate and always updated.

• Principle of limitation of the term of conservation: the personal data will only be maintained in a way that allows the identification of the User for the time necessary for the purposes of their treatment.

• Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.

• Principle of proactive responsibility: The person responsible for the treatment will be responsible for ensuring that the above principles are met.

Personal data categories

The categories of data that are treated in Graspway are only identifying data. In no case, special categories of personal data are treated within the meaning of Article 9 of the GDPR.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Graspway undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

The User will have the right to withdraw their consent at any time. It will be as easy to withdraw consent as to give it. As a general rule, withdrawal of consent will not condition the use of the Website.

In the occasions in which the User must or can provide his data through forms to make inquiries, request information or for reasons related to the content of the Website, he will be informed in case the completion of any of them is mandatory because they are essential for the proper development of the operation performed.

Purposes of the treatment to which the personal data are destined

The personal data are collected and managed by Graspway in order to facilitate, expedite and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fill out or to meet a request or query.

Likewise, the data may be used for a commercial, personalization, operational and statistical purpose, and activities of the corporate purpose of Graspway, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as improve the quality, operation and navigation of the Website.

When the personal data is obtained, the User will be informed about the specific purpose or purposes of the treatment to which the personal data will be used; that is, the use or uses that will be given to the information collected.

Periods of retention of personal data

Personal data will only be retained for the minimum time necessary for the purposes of its treatment and, in any case, only during the following period: 2 years, or until the User requests its deletion.

When the personal data is obtained, the User will be informed about the period during which the personal data will be kept or, when that is not possible, the criteria used to determine this period.

Recipients of personal data

The personal data of the User will not be shared with third parties.

In any case, when the personal data is obtained, the User will be informed about the recipients or categories of recipients of the personal data.

Personal data of minors

Respecting the provisions of articles 8 of the GDPR and 13 of the RDLOPD, only those over 14 years of age may grant their consent for the processing of their personal data in a lawful manner by Graspway. If it is a child under 14 years of age, the consent of the parents or guardians will be necessary for the treatment, and this will only be considered lawful to the extent that they have been authorized.

Secrecy and security of personal data

Graspway undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, in a way that guarantees the security of personal data and prevents the destruction, loss or accidental or unlawful alteration of personal data transmitted, preserved or otherwise processed, or unauthorized communication or access to such data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the data is transmitted between the server and the User, and in feedback, fully encrypted or encrypted.

However, because Graspway cannot guarantee the inexputability of the internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a violation of The security of personal data that is likely to pose a high risk to the rights and freedoms of natural persons. Following the provisions of article 4 of the GDPR, it is understood as a violation of the security of personal data any breach of security that causes the accidental, unlawful or unlawful destruction, loss or alteration of personal data transmitted, kept or otherwise treated, or unauthorized communication or access to such data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and guarantee through a legal or contractual obligation that said confidentiality is respected by his employees, associates, and any person to whom the information.

Rights derived from the processing of personal data

The User has about Graspway and may, therefore, exercise the following rights recognized in the GDPR before the Data Controller:

• Right of access: It is the right of the User to obtain confirmation of whether Graspway is treating their personal data or not and, if so, to obtain information about their specific personal data and the treatment that Graspway has performed or carried out, as well as, among other, of the available information on the origin of said data and the recipients of the communications made or planned of the same.

• Right of rectification: It is the right of the User to modify their personal data that prove to be inaccurate or, taking into account the purposes of the treatment, incomplete.

• Right of deletion ('the right to be forgotten'): It is the right of the User, provided that the current legislation does not establish otherwise, to obtain the deletion of their personal data when they are no longer necessary for the purposes for which they were collected or treated; the User has withdrawn his consent to the treatment and this does not have another legal basis; the User opposes the treatment and there is no other legitimate reason to continue with it; personal data has been treated illegally; personal data must be deleted in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a child under 14 years old. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its application, must take reasonable measures to inform those responsible for processing the personal data of the interested party's request to delete any link to that personal data

• Right to limit the processing: It is the right of the User to limit the processing of their personal data. The User has the right to obtain the limitation of the processing when he challenges the accuracy of his personal data; the treatment is illegal; the Data Controller no longer needs personal data, but the User needs it to make claims; and when the User has opposed the treatment.

• Right to data portability: In the event that the processing is carried out by automated means, the User will have the right to receive from the Person Responsible for the processing their personal data in a structured format, for common use and mechanical reading, and to transmit them to another responsible of treatment Whenever technically possible, the Data Controller will directly transmit the data to that other person in charge.

• Right of opposition: It is the right of the User not to carry out the processing of their personal data or to cease the processing of them by Graspway.

• Right not to be the subject of a decision based solely on automated processing, including profiling: It is the right of the User not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, existing unless the current legislation establishes otherwise.

Thus, the User may exercise their rights through written communication addressed to the Data Controller with the reference 'GDPR-www.graspway.com', specifying:

• Name, surname of the User and copy of the ID. In cases where the representation is admitted, identification by the same means of the person representing the User will also be necessary, as well as the document proving the representation. The photocopy of the DNI may be substituted, by any other means valid in law that proves the identity.

• Request with the specific reasons for the request or information that you want to access.

• Address for the purpose of notifications.

• Date and signature of the applicant.

• Any document that accredits the request you make.

This application and any other attached document may be sent to the following address and / or email:

Postal Address:

Calle Salvatierra 4, 28034, Madrid (Spain).
Email: info@opensistemas.com

Links to third party websites

The Website may include hyperlinks or links that allow access to websites of third parties other than Graspway, and therefore are not operated by Graspway. The owners of these websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Claims before the supervisory authority

In the event that the User considers that there is a problem or violation of the regulations in force in the way in which their personal data is being processed, they will have the right to effective judicial protection and to file a claim with a control authority, in particular, in the State in which you have your habitual residence, place of work or place of the alleged infringement. In the case of Spain, the control authority is the Spanish Agency for Data Protection (https://www.aepd.es/).

Acceptance and changes in this privacy policy

It is necessary that the User has read and is in accordance with the conditions on the protection of personal data contained in this Privacy Policy, as well as that he accepts the processing of his personal data so that the Responsible for the processing can proceed to it in the form, during the deadlines and for the purposes indicated. The use of the Website will imply acceptance of its Privacy Policy.

Graspway reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Agency for Data Protection. Changes or updates to this Privacy Policy will be explicitly notified to the User.

This Privacy Policy was updated on September 16, 2019 to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to treatment of personal data and the free circulation of this data (GDPR).